While facing a federal tax audit can be risky in any circumstance, it can be especially risky if you have concerns about tax code compliance. For high-income and high-net-worth taxpayers, non-compliance with the Internal Revenue Code can create substantial exposure—including exposure to liability for interest and penalties. With this in […]
Category: Audits
If you are like most high-income and high-net-worth taxpayers, you rely on professionals to help make sure you pay what you owe (while also making sure you pay as little as possible). So, what happens if one of your tax professionals makes a mistake? Are you liable to the Internal […]
If you received an unfavorable audit determination from the Internal Revenue Service (IRS), challenging the outcome of your audit will involve filing an appeal. In most cases, this starts with filing a “protest” with the appropriate IRS office. Before you file, however, you need to ensure that doing so is […]
The Internal Revenue Service (IRS) routinely targets high-income and high-net-worth taxpayers suspected of using abusive tax shelters to evade federal tax liability. Abusive tax shelters fall into several categories, the broadest of which are the IRS’ “Listed Transactions.” As federal tax audits and investigations targeting Listed transactions can present substantial […]
On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to conduct “dozens of audits on business aircraft involving personal use” throughout the year. Citing the IRS’ additional funding under the Inflation Reduction Act, the News Release quotes IRS Commissioner Danney Werfel as stating: “With expanded resources, […]
In a recent news release, the Internal Revenue Service (IRS) announced that it intends to shift its focus to targeting wealthy individuals and business partnerships beginning in fiscal year (FY) 2024. The news release also identifies three specific “priority areas” in which the IRS intends to focus its enforcement efforts […]
On September 8, 2023, the Internal Revenue Service (IRS) announced a “sweeping effort” to enhance its tax collection and enforcement efforts. Among other strategies, the announcement states that the IRS intends to “shift attention to wealthy from working-class taxpayers” while also placing greater emphasis on enforcing partnerships and partners’ tax […]
Audits conducted by the Internal Revenue Service (IRS) can have a variety of outcomes. In some cases, they can simply confirm taxpayers’ compliance with the Internal Revenue Code. In others, they can lead to liability for back taxes, interest and penalties; and, in others still, they can trigger criminal tax […]
The Internal Revenue Service (IRS) has recently issued multiple notices and proposed regulations focused on combating tax preparer fraud and cracking down on abusive tax schemes facilitated by promoters. IRS Criminal Investigation (IRS CI) has recently issued multiple press releases highlighting its efforts to target tax preparers and promoters as […]
Through its rulemaking authority, the Internal Revenue Service (IRS) has identified several types of transactions as “listed transactions.” As the IRS explains, a listed transaction is any transaction that is, “the same as, or substantially similar to, one that the IRS has determined to be a tax avoidance transaction and […]